The Complaint alleges that the Offering Documents issued in connection with the IPO were negligently prepared and, as a result, contained untrue statements of material fact or omitted to state other facts necessary to make the statements made not misleading and was not prepared in accordance with the rules and regulations governing their preparation. Specifically, the Complaint alleges that the Offering Documents made false and/or misleading statements and/or failed to disclose that: (i) Expensify’s revenue growth was highly susceptible to structural and macroeconomic headwinds; (ii) as a result, the Company overstated the efficacy of its business model and the likelihood it would meet the long-term growth projections touted in the Offering Documents; (iii) accordingly, the Company’s post-IPO financial position and/or business prospects were overstated; and (iv) as a result, Defendants’ statements about the Company’s business, operations, and prospects were materially false and misleading and/or lacked a reasonable basis at all relevant times.